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Dow Chemical Company, Freeport Texas

Letter from Dan Pearson to David Gardiner

P.O. Box 13087 . Austin, Texas 78711-3087 . 512/239-1000
Protecting Texas by Reducing and Preventing Pollution

May 10, 1996

Mr. David Gardner
Assistant Administrator
Office of Policy, Planning & Evaluation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460

Dear Mr. Gardner:

The Texas Natural Resource Conservation Commission (TNRCC) has reviewed and fully supports the Project XL proposal submitted by Dow  Chemical Company for its Freeport facility. The Dow proposal commits to innovations that will result in a 25% reduction in the unit ratio of liquid halogenated wastes burned per pound of associated product and reductions in the number of Boiler and Industrial Furnace (BIF) units in liquid service. The Dow proposal also includes a commitment to complete a stack sampling program for dioxins and furans to identify reduction opportunities. To meet these commitments, Dow will develop and implement alternatives to combustion; construct new production processes; and upgrade, replace, or discontinue operation of certain BIF units. Overall, we believe the project will demonstrate that equivalent environmental benefits can be achieved without the burden imposed by current regulations.

Dow and the TNRCC recognize that the proposed Maximum Achievable Control Technology rule and other proposed regulations will be published sometime in the future and that these rules may impact some aspects of the proposal. However, Dow would like to be proactive and move ahead in an effort to achieve better environmental performance, flexibility, and efficiency. In addition, because Texas has a majority of the nation's BIF units, the TNRCC feels it is important to encourage innovation in this area of disposal.

As a charter member of the TNRCC's Clean Industries 2000 Dow Freeport has committed to reduce Toxic Releases Inventory releases by 50% (3,560 tons) by the year 2000 from a baseline (1988) amount of 5,888 tons. In addition, Dow has an effective 15-member Citizens' Advisory Panel which meets monthly and has been in existence for almost five years.

The TNRCC appreciates the opportunity to work with Dow on this proposal and the efforts by Dow towards responsible environmental stewardship. The TNRCC encourages approval of the Dow Project XL by the U.S. Environmental Protection Agency and looks forward to working with you in this regard. Please let us know if we can provide you with any additional information.


Dan Pearson
Executive Director

cc: Ms. Sandy Hendson, Dow Chemical Company, Freeport
Mr. Richard A. Olson, Dow Chemical Company, Freeport
Mr. Jim Sales, U.S. Environmental protection AGency, Region 6, Dallas

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